Taxes on railroad fuel
CSX Transportation v. Alabama Department of Revenue
In brief
CSX won the right to challenge Alabama’s diesel taxes, but the Court did not decide whether they discriminate.
- Where it stands
- Decided
Decided 7-2 · February 22, 2011 · Opinion by Justice Kagan
- What it’s about
- CSX challenged Alabama’s sales and use taxes on diesel fuel, which applied to railroads but exempted competing transportation businesses.
- Who it affects
- CSX may continue its federal challenge in the Eleventh Circuit; the Supreme Court did not decide whether Alabama’s taxes discriminate.
Summary: written with AI from the case record.
What it's about
The Supreme Court ruled that federal railroad law lets CSX bring the challenge, overturned the Eleventh Circuit’s ruling (reversed it), and sent the case back to that court (remanded); it did not decide whether the taxes discriminate.
Federal law bars certain state taxes that discriminate against railroads.
Question presented
Can the CSX Transportation railroad company challenge an Alabama state tax of its purchase of diesel fuel?
What the Court decided
Holding
CSX may challenge Alabama’s sales and use taxes under §11501(b)(4). 318, reversed and remanded.
- Result
- Reversed
The vote
From the opinions
“I would hold that, to violate §11501(b)(4), a tax exemption scheme must target or single out railroads by comparison to general commercial and industrial taxpayers.”
What's next
The case returns to the Eleventh Circuit for further proceedings on CSX’s challenge, including whether the taxes discriminate.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - CSX Transportation, Inc. v. Alabama Department of Revenue
Opinion added: CSX Transp.
More questions
- What did Justice Thomas argue?
- He said CSX should have to show that Alabama’s tax exemptions targeted railroads compared with other commercial and industrial taxpayers.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.